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CORRESP
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filename1.htm

    d812558_corresp.htm

              September
                21, 2007

    United
      States

    Securities
      and Exchange Commission

    Division
      of Corporation Finance

    100F
      Street, N.E

    Washington,
      D.C. 20549

    Attention:   Linda
      Cvrkel

    Re:  Nordic
      American Tanker Shipping Ltd.

    Form
      20-F for the year ended December
      31, 2006

    Filed
      June 29,
      2007

    File
      No. 1-13944

    Dear
      Ms.
      Cvrkel:

    We
      represent Nordic American Tanker Shipping Limited (the “Company”).  By
      letter dated August 9, 2007, the Staff of the Securities and Exchange Commission
      (the “Staff”) provided comments to the Company’s Annual Report on Form 20-F for
      the fiscal year ended December 31, 2006. The Company responded to the Staff's
      comments by letter dated August 23, 2007. The Staff provided further
      comments to the Company by letter dated September 7, 2007.

    The
      Company’s responses, together with the Staff’s comments, are set forth
      below.

              1.

              We
                note your response to prior comment #2.  Although we do not
                believe any adjustment is warranted for the current period based
                on the
                immaterial amounts involved and your SAB analysis, we believe that
                your
                accounting policy should be revised prospectively to comply with
                the
                guidance in EITF 91-9.  Alternatively, if you choose not to
                revise your accounting policy to comply with the guidance in EITF
                91-9, we
                would expect all future filings to include disclosure indicating
                that your
                policy for expense recognition does not comply with the guidance
                in EITF
                91-9 but the impact of this departure from generally accepted accounting
                principles was not material to any of the annual or quarterly periods
                presented in your financial statements.  We would expect this
                disclosure to be provided in the notes to your financial statements
                in all
                future annual and quarterly filings, as
                applicable.

    The
      Company advises the Staff that it undertakes to revise its accounting policy
      to
      comply with the guidance in EITF 91-9 or, in the alternative, to disclose in
      the
      notes to its financial statements included in the Company’s annual reports and
      reports filed under cover of Form 6-K that the Company’s policy for expense
      recognition does not comply with the guidance in EITF 91-9 but the impact of
      this departure from generally accepted accounting principles was not material
      to
      any of the annual or quarterly periods presented in the Company’s financial
      statements.

    The
      Company understands that it is responsible for the adequacy and accuracy of
      the
      disclosure in its filing; Staff comments or changes to disclosure to Staff
      comments do not foreclose the Commission from taking any action with respect
      to
      the filing; and the Company may not assert Staff comments as a defense in any
      proceeding initiated by the Commission or any person under the federal
      securities laws of the United States.

    Please
      feel free to contact the undersigned at (212) 574-1223, or Christine Westbrook
      of this office at (212) 574-1371, with any questions or comments.

              Very
                truly yours,

              SEWARD
                & KISSEL LLP

              /s/
                Seward & Kissel LLP

              By:  Gary
                J. Wolfe

              cc:

              Herbjørn
                Hannson

              Chief
                Executive Officer

              Nordic
                American Tanker Shipping Limited

              Ingebret
                Hisdal

              Partner,
                Deloitte AS

    SK
      01318 0002
      812558